Episode 267 — DOJ Escalates Compliance Program Requirements
The Justice Department is rapidly pushing corporations to a new level of compliance. We are witnessing a watershed moment – DOJ is raising the bar on expectations surrounding corporate compliance programs. It would be a mistake, however, to interpret DOJ’s recent changes as limited to compliance compensation and preservation of internal communications data.
When considered together, the changes to the Corporate Enforcement Policy, the Evaluation of Corporate Compliance Programs, and the issuance of the Three-Year Pilot Program on Compensation Incentives and Clawbacks, reflect a broad set of expectations governing corporate compliance programs.
In this Episode, Michael Volkov reviews recent updates to DOJ’s compliance program requirements.